How to Prepare for the New Stormwater MSGP if You Have Never Sampled Before
In part one of our blog series on the Multi-Sector General Permit for Stormwater (MSGP), we summarized the key changes in the proposed 2020 MSGP for Stormwater. As the days tick by and we wait for the rule to become final, there are some key things you should keep in mind so you can be prepared – especially when you have never sampled before. Below is a list of lessons learned that will help you get ready.
How to prepare for the 2020 MSGP for Stormwater:
Cleaning up your outside storage area can make a big difference
Start as soon as possible for more control and fewer surprises; in most cases, it’ll be less expensive in the long run.
Know the answers to the questions you will have to answer BEFORE the new rule takes effect.
Know how to collect representative samples of stormwater runoff.
Know what a representative sample means.
Determine your drainage areas, discharge locations, and sampling locations.
Basic Best Management Practices (BMPs). Housekeeping, Preventive Maintenance… are you doing them? Are you REALLY?
Desiccated pavement – the gift that keeps on giving. Asphalt and concrete in poor condition will collect dirt and metals and release during the rain. Reseal or repave – this can reap great rewards.
Conduct observations, during dry and wet weather. Both conditions tell stories.
Use secondary containment as much as practicable.
Roofs are likely sources of zinc and other metals, depending on construction materials and whether HVAC and other equipment is on roofs (in California, this is usually a Yes).
Get things under the roof.
Evaluate whether you have run on; do something about it if you can. Document with photos and sample analysis if you can’t.
Train your employees! This is the most important BMP.
Conduct a detailed pollutant source assessment to identify additional parameters to sample for, especially with respect to receiving water impairments and TMDL requirements.
Make sure you know where the stormwater that discharges from your site is going – receiving water is very important and may cause you to meet additional requirements or for the benchmark to be much lower and harder to meet.
3rd party (Non-Government Organizations) will likely increase, especially in states that did not require stormwater sampling before.
Foresee pollutant issues/exceedances prior to sampling and proactively look into mitigation options. For instance, if a facility knows that they have numerous galvanized structures, downspouts, etc., zinc as a potential pollutant should be on their radar and they should understand/explore their options. Galvanized roofs and downspouts can easily put you over the benchmarks even if zinc is not part of your industrial operations.
Work with someone with experience and who offers a partnership in finding solutions.
For assistance with management, MSGP compliance, and industrial stormwater permitting, contact us or call (800) 508-8034 today to speak with one of our experienced stormwater consultants.
Blog Author
Jodie Crandell, QISP, QEP, TOR
Senior Project Manager
KERAMIDA Inc.
Contact Jodie at jcrandell@keramida.com.